Meyer v. U.S. Coast Guard

The court rules that § 6001 of the Resource Conservation and Recovery Act (RCRA) does not waive the federal government's sovereign immunity to civil penalties imposed by states. The court initially notes that the United States cannot be sued without its consent, that any waiver of consent must be clearly and unambiguously expressed, and that purported waivers must be read narrowly. Applying these requirements, the court holds that the Coast Guard is immune from a suit filed by North Carolina to recover a $10,000 administrative penalty assessed for the Coast Guard's alleged failure to file a RCRA Part B permit application for its hazardous waste facility near Elizabeth City. RCRA § 6001 does not clearly and unambiguously state that the federal government will be subject to fines and other penalties by states. A strict construction of the statute limits the waiver to those penalties specifically mentioned — injunctive relief and sanctions imposed by courts. This interpretation is further supported by RCRA's legislative history and by cases holding that RCRA § 6001 does not waive the federal government's immunity from criminal sanctions or state strict liability statutes.